Process Safety Management of highly hazardous chemicals - parts cleaning station involving flammable liquids.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

July 15, 1994

Mr. Charles Knudsen
Cryovac
2835 24th Avenue
Marion, Iowa 52302

Dear Mr. Knudsen:

This is in response to your April 12 letter, requesting interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals standard, 29 CFR 1910.119 with respect to a parts cleaning station (PCS) involving flammable liquids as described in the scenario below. Please accept our apology for the delay in responding. Your question and our reply follow.

Scenario:

Clarifications of the OSHA standards, 29 CFR 1910.109 and 29 CFR 1910.119.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

August 4, 1994

Mr. Curtis W. Rankins
Director of Health and Safety
Laidlaw Environmental Services
407 Burton Road
Lexington, South Carolina 29072

Dear Mr. Rankins:

This is in response to your May 9 letter to Roger Clark, former Director of the Directorate of Compliance Programs. In your letter, you requested clarifications of the OSHA standards, 29 CFR 1910.109 and 29 CFR 1910.119.

In the following, please find your specific questions and our answers.

Process Safety Management of Highly Hazardous Chemicals standard as it may apply to the batch chemical processes.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

August 8, 1994

Mr. David W. Spencer Baker Performance Chemicals, Inc. 3920 Essex Lane P.O. Box 27714 Houston, Texas 77227-7714

Dear Mr. Spencer:

This is in response to your June 16 letter requesting clarification of the Process Safety Management (PSM) of Highly Hazardous Chemicals (HHCs) standard, 29 CFR 1910.119 as it may apply to the batch chemical processes as described in the scenario below. Your question and our reply follow. Please accept our apology for the delay in responding.

HHC as it applies to tank battery.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 29, 1994

Mr. Forrest W. Frazier Plains Resources 1600 Smith Street Houston, TX 77002

Requesting interpretation of the Process Safety Management Standard of Highly Hazardous Chemicals Standard.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

November 7, 1994

Mr. Pete Mutschler Cenex Supply & Marketing, Inc. P.O. Box 64089 St. Paul, MN 55164-0089

Dear Mr. Mutschler:

This is in response to your July 12 letter, forwarded to us by our Denver Regional Office, requesting interpretation of the Process Safety Management Standard (PSM) of Highly Hazardous Chemicals (HHCs) standard, 29 CFR 1910.119. Your scenario and associated questions and our corresponding replies follow. Please accept our apology for the delay in responding.

Pressure vessels used at oil and gas extraction/production facilities and applicability of 29 CFR 1910.106

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

 

The applicability of Process Safety Management standard to a 50% solution of Hydroxylamine.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 11, 1995

Mr. Jeffrey O. Brown
Howard Hall Division R.W.
Greeff & Co., Inc.
777 West Putnam Avenue
Greenwich, Connecticut 06830

Dear Mr. Brown:

This is in response to your March 20, 1995 letter requesting an interpretation regarding the applicability of Process Safety Management standard, 29 CFR 1910.119, to a 50% solution of Hydroxylamine (CAS #7803-49-8).

Clarification regarding the applicability of PSM to chemical distributors that merely store, transfer, and/or non mechanically blend flammable liquids.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

August 11, 1995

Joe Hudman, Ph.D, CHMM
Hudman & Associates, Inc.
P.O. Box 1506
Conroe, Texas 77305

Dear Mr. Hudman:

This is in response to your April 7, 1995 letter requesting interpretation of the Process Safety Management (PSM) standard 29 CFR 1910.119. Specifically, you requested clarification regarding the applicability of PSM to chemical distributors that merely store, transfer, and/or non mechanically blend flammable liquids.

Interpretation of the Process Safety Management Highly Hazardous Chemicals standard.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

November 3, 1995

Mr. Paul J. Lawonn
MRA-The Management Association, Inc.
235 North Executive Drive
Suite 100
Brookville, WI 53005-7591

Dear Mr. Lawonn:

This is in response to your September 15 letter requesting an interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals (HHC's) standard, 29 CFR 1910.119. Specifically, you requested clarification as to whether the three processes enclosed with your letter would be covered by the PSM Standard. Your process diagrams are enclosed to facilitate our response.

PSM coverage of utility systems; whether 1910.269 preempts the PSM standard for power generation facilities that serve covered processes.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.


January 31, 2008

Mr. Howard J. Feldman
Director, Regulatory Analysis and Scientific Affairs
American Petroleum Institute
1220 L Street, NW
Washington, DC 20005-4070

Dear Mr. Feldman: